Anti- Slavery Statement
Statement under Section 54(1) of the UK Modern Slavery Act 2015 for Smarter Technologies Group
Limited and all its relevant group of companies.

Last Updated: May 2022.

Documentation HistoryAuthor
Bid ManagerGeneral Counsel

Update byElaine Glock
Matt Hunt

VersionV0.1
V1.0

Date
30/07/2020
09/05/2022

Smarter Technologies Group Limited | 1 Austin Park, Yeoman Road, Ringwood, Hampshire, BH24 3FG
Registered in England and Wales with company number 12075211. VAT Registration 346 8009 90
t: 0330 223 5000 e: enquiries@smartertechnologies.com w: www.smartertechnologies.com

Commercial in confidence

Page 2 of 6

Introduction
Modern slavery is a crime and violation of fundamental human rights. It takes various forms, such as slavery,
servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of aperson’s liberty by another in order to exploit them for personal or commercial gain.
We have a zero-tolerance approach and are committed to acting ethically and with integrity in all our businessdealings and relationships and to implementing and enforcing procedures to ensure modern slavery is not taking
place anywhere in our own business or in any of our supply chains.

Organisation Structure
Smarter Technologies Group Limited is a limited company registered in England and Wales, with Company
Registration number 12075211.

Our Business
Our principal activities are to assist with all aspects of Digital Transformation required within the public sector
markets, with clients ranging from Central to Local Government, MoD, DEFRA, DTI, NHS Trusts. Our annual
turnover is in excess of £14m. To find out more about Smarter Technologies Group Limited please visit
smartertechnologies.com

The parts of our business and supply chain where risks of modern slavery are highest
In order to provide services to our clients we work with a range of suppliers including, but not limited to,professional service firms, utility suppliers, IT vendors, consultants, industry business partners and technology
platform providers.

Our Policy on Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any
part of our business. Our Anti-slavery Statement reflects our commitment to acting ethically and with integrity inall our business relationships and in relation to implementing and enforcing effective systems and controls toensure slavery and human trafficking is not taking place anywhere in our supply chains.
We also make sure our suppliers are aware of our policies and adhere to the same high standards.

Due Diligence Processes in place to manage and prevent risks of modern slavery and HumanTrafficking
As part of our initiative to identify and mitigate risk we have in place systems, due diligence processes andprocedures to:

Mitigate the risks in recruitment (through our recruitment and vetting policies). We conduct eligibility towork in the UK checks for all employees to safeguard against human trafficking or individuals being forced towork against their will.
Identify, assess and monitor potential risk areas in our supply chains.

Reduce the risk of slavery and human trafficking occurring in our supply chains; andSmarter Technologies Group Limited | 1 Austin Park, Yeoman Road, Ringwood, Hampshire, BH24 3FG
Registered in England and Wales with company number 12075211. VAT Registration 346 8009 90
t: 0330 223 5000 e: enquiries@smartertechnologies.com w: www.smartertechnologies.com

Commercial in confidence

Page 3 of 6

Encourage and protect whistle blowers.

Supplier Adherence to our Values
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain to comply withour values. For example, if we find evidence of a failure to comply with our policies which contain or reflect antislavery measures, we will immediately seek to terminate our relationship with the relevant supplier.

Training and capacity building of staff around modern slavery
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chainsand our business, we provide regular training to our staff.

Our effectiveness in Combating Slavery and Human Trafficking
We intend to use key performance indicators (KPls) to measure how effective we have been to ensure thatslavery and human trafficking is not taking place in any part of our business or supply chains. This statement ismade pursuant to section 54(I) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking
statement for the current financial year.

Adherence to local and national lawsSTTL make sure that it adheres to all laws in place be they National or local to location of work being carried out.

Freedom of workers to terminate employment
All employees have the right to terminate their employment should they so desire, with a four week notice
period. As stated within their contract of employment

Freedom of movement
All STTL employees have freedom of movement to work where they are required to do so, be it in the office or ata customers site where work is being carried out.

Freedom of association
All STTL have the right to join a trade union, to engage in free speech or to participate in debating societies,
political parties, or any other club or association, including religious denominations and organizations, fraternities,and sport clubs and not to be compelled to belong to an association should they choose to do so.

Prohibits any threat of violence, harassment and intimidation
STTL states within its equal opportunities policy that ALL behaviour such as Violence, Threats and Intimidation are
not acceptable and depending on the severity will result in a written warning with training for improvement to beprovided or the termination of employment.

Prohibits the use of worker-paid recruitment fees
STTL does not make its Workers recruitment fees or other related fees for their employment.

Approved by the board of directors (or equivalent management body)
STTL can confirm that the Modern Slavery documentation has been approved by the board of Directors.

Smarter Technologies Group Limited | 1 Austin Park, Yeoman Road, Ringwood, Hampshire, BH24 3FG
Registered in England and Wales with company number 12075211. VAT Registration 346 8009 90
t: 0330 223 5000 e: enquiries@smartertechnologies.com w: www.smartertechnologies.com

Commercial in confidence

Page 4 of 6

Accessible via a prominent place on web site homepage
Our Anti – Slavery Policy can be found with our statement on the front page of our company website –www.smartertechnologies.com

Policy reflecting modern slavery
Our Anti – Slavery Policy can be found with our statement on the front page of our company website –www.smartertechnologies.com

Ed Walker
Director, Smarter Technologies Group Limited

Smarter Technologies Group Limited | 1 Austin Park, Yeoman Road, Ringwood, Hampshire, BH24 3FG
Registered in England and Wales with company number 12075211. VAT Registration 346 8009 90
t: 0330 223 5000 e: enquiries@smartertechnologies.com w: www.smartertechnologies.com

Commercial in confidence

Page 5 of 6